Memorandum Findings of Fact and Opinion
In Docket No. 58437 respondent determined a deficiency in Federal income taxes for the calendar year 1950 in the amount of $2,129.51. That part of this deficiency is here in issue which arises from respondent's determination that a premium received by the corporate taxpayer on a mortgage note was not amortizable but constituted income in its entirety in the year of its receipt...
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